“APAAR ID: Future of education system – benefits, challenges, and data privacy concerns

According to Ministry of Education (MoE), APAAR is an acronym for Automated Permanent Academic Account Registry. It is part of the ‘One Nation, One Student ID’ program launched by the Indian government, aligning with the new National Education Policy (NEP) of 2020. APAAR ID is a unique 12-digit code that is intended to help students digitally store, manage, and access all their academic credits, including scorecard, marksheets, grade sheets, degrees, diplomas, certificates, training details and co-curricular accomplishments.

Additionally, other education-related services such as admissions, scholarships, concessions, credit management, credit transfer form one institution to another, internships, certifications, job applications, and verification of academic records, are intended to be mapped to APAAR ID.

In other words, what PAN is to an Indian taxpayer, APAAR ID is that to an Indian learner. Except, there is a key difference – while your future employer cannot look into your prior income details using your PAN, a future employer or education provider could look into your prior academic credits (or what you have learnt so far) and your academic performance (or how well you have learnt) by using your APAAR ID.

Why students apparently need one

The MoE’s APAAR website (https://apaar.education.gov.in/faqs) states that APAAR ID provides a student with a lifelong academic identity, with all academic records available through a central repository. This is intended to enable the student to easily move from one institution to another, during their entire education journey.

Additionally, APAAR intends to also capture co-curricular details and any learning achievements during the academic life of the student. The overall intention is to help create a complete portfolio of a student’s learning throughout their life, be it formal education through academic institutions, or continuous learning through skilling organisations, or co-curricular learning through other institutions. This seems to align with NEP 2020’s vision for enabling holistic learning.

To understand this deeper, consider a student progressing through schooling where they undergo curricular, co-curricular and extra-curricular learning experiences. Curricular learning is captured in marksheets and report cards, which is then provided to their parents. Co-curricular and extra-curricular learning is often not captured in these official transcripts, and end up as separate certificates or awards, which parents and students are expected to preserve.

As the student grows into a young professional, it is the burden of the student to provide their future employers with the picture of their holistic education journey. In other words, on the one hand, a student needs to piece together their portfolio, consisting of their official curricular transcripts, along with the co-curricular or extra-curricular milestones. For the few who choose to misuse this, it leads to proliferation of fake certificates in the educational ecosystem. On the other hand, government and its agencies do not have a complete picture of the educational attainment levels of their polity.

APAAR ID aims to solve for both these problems – i.e. student’s holistic portfolio and holistic education insights to government. It achieves this by bringing together two separate digital infrastructure solutions that already existed – DigiLocker, which provides a way for citizens to retrieve certified electronic copies of educational certificates, and Academic Bank of Credits (ABC), where academic institutions are required to publish student’s learning data via the National Academic Depository (NAD).

In other words, the NAD is like the central bank where an educational or skilling institution reports any learning certificate as and when one is issued to any Indian learner. ABC is like each student’s passbook of all learning certificates they have received from any institution, throughout their student life.

DigiLocker is where the certificate is stored electronically, along with all other official documents such as Driving License, insurance cards, ABHA card, COVID vaccination certificates and more. DigiLocker is protected via Aadhaar-enabled access.

By using APAAR ID, a student would be able to see their ABC passbook, which contains the digital versions of their original learning certificates, extracted from DigiLocker. The student could then share that passbook with any further education provider or future employer, to validate and recognize their prior learning details. They may not have to physically submit their marksheets which they do today. At least, this is the promise of APAAR ID from the student perspective.

Here’s why government apparently needs it

From the government perspective, MoE and its authorized agencies could look at the aggregated data of educational attainment across all students, or at an individual learner level, track our nation’s progress towards NEP 2020 goals, and could plan or act accordingly to address any issues or shortcomings.

As much as APAAR is in the news today, it is not the MoE’s first attempt at building such a database. Unified District Information on School Education (UDISE), one of the largest education management information systems on school education, was initiated in 2012-13 by MoE, by integrating previously existing DISE for elementary education and SEMIS for secondary education.

Later enhanced to UDISE+, it primarily acts as the official source for School Education Statistics, aimed at improving MoE’s planning and decision-making with respective to national education. While UDISE+ data was mostly related to school setup, infrastructure, compliance, financial details, faculty details and courses offered, it also captured student’s demographic details and special needs requirements.

When it came to academic performance, UDISE+ only captures basic details such as grade studied this year, previous year and whether the student was promoted or failed. No data about student’s detailed curricular, co-curricular or extra-curricular learning experiences are captured in UDISE+. Also, UDISE+ is still limited to school level of education, and is not linked to tertiary educational journey of the student. One point to note here, UDISE+ also captures Aadhaar details of students and teachers, but that field is completely optional in UDISE+.

While systems like UDISE+ help the MoE to assess educational infrastructure, educational access and equity, there were no systems that could help the government to understand larger aggregated holistic-learning or educational-attainment trends of its polity – in other words, MoE needs a real-time birds-eye-view of our national education in action. APAAR ID and ABC claim to enable MoE with this capability.

Is APAAR too good to be true

The intention of having an official and verifiable data bank of academic achievements for every citizen seems to be in the right direction of eGovernance. After all, we have already seen the benefits of going digital with ATMs disrupting retail banking, or online booking of railway tickets (a system that is still evolving), or Aadhaar-based direct benefit transfers, or UPI-enabled instant transactions, and much more. Just as we saw with those other systems going digital, we seem to have identified certain gaps with the APAAR ID implementation well.

First, constitutionally speaking, Aadhaar is optional for enrolling any student in Indian school education, as upheld by the Supreme Court’s ruling in Justice (Retd.) K.S. Puttaswamy v. Union of India [2019 (1) SCC 1]. Even with UDISE+, as I stated above, Aadhaar was an optional data entry field, and UDISE+ data capture form even recommends the following: “For the Students who don’t have Aadhaar Number, ‘9999 9999 9999’ (12 times 9) need to be entered in UDISE+ Online Application. Aadhaar Number is non-mandatory field.”.

However, with the introduction of APAAR ID and its hard-linking to Aadhaar, MoE appears to have created a back-door or proxy-mandate for capturing student’s Aadhaar. On a side note, United States’ Social Security Number (SSN) which is a long-standing infrastructure and inspiration behind Aadhaar, is clearly called out as optional requirement by U.S. Department of Education guidelines – “Information on the Rights of All Children to Enroll in School”. India lacks such clear direction with respect to Aadhar requirement for schooling, which led to the above-mentioned legal battle in the first place.

Second, MoE’s roll-out of APAAR ID wherein it instructed Chief Secretaries of States and UTs to pseudo-mandate setup of APAAR IDs of all enrolled students (underplaying that it is voluntary), appears to have directly contradicted with the Constitutional stance of Aadhaar being optional to enrol in school education. Additionally, CBSE also instructing its affiliated schools to ensure “100% saturation” of APAAR IDs among its students appears to comply with the above pseudo-mandate by MoE.

Third, such a roll-out subverting established legal and constitutional channels is apparently not happening for the first time in India. Even with Aadhaar, as pointed out by identity researcher Kaliya Young, UIDAI was found to have initially worked on Aadhaar roll-out without first putting the necessary legal or regulatory framework – this seems to eerily resemble the approach being taken with APAAR ID roll-out.

Fourth, there is minimal information of how APAAR ID-enabled access to ABC, gives access to the student’s official academic achievement documents stored in his or her DigiLocker. Would those documents be copied over to APAAR ID enabled dashboard? If so, how will those ABC-stored copies be protected and secured against cyber-attacks? After all, we are talking about the entire nation’s academic data bank.

Fifth, while parental consent is required for APAAR ID registration, there are concerns about the efficacy of obtaining the same, especially whether such parental consent would be verifiable under the Section 9(1) of the Digital Personal Data Protection Act (DPDP Act). Also, while there is some information on how this parental consent can be withdrawn, Aadhaar data that has already been retrieved to create APAAR ID will be retained in ABC.

Digital freedom advocacy groups such as Software Freedom Law Center and Internet Freedom Foundation have highlighted this and many other privacy concerns related to excessive data collection and potentially unsecure data sharing that APAAR ID could enable. This needs more scrutiny especially given that ABC, on its website, seems to indicate that it intends to make this data available to third-party platforms – apparently to “deliver unique advantages including personalized learning for early education, targeted interventions for K12 platforms, personalized study plans for test preparation, and skill gap analyses with industry-relevant content for upskilling programs”.

A requirement, but needs a proper roll-out

All the arguments against APAAR ID do not seem to question the need for its existence. There appears to be an unsaid or unwritten consensus that APAAR ID or something like that is needed. The voices of reason against APAAR ID all appear to focus on two specific areas – how APAAR ID is being rolled out silently bypassing Constitutional rights and without first establishing proper legal frameworks, and how APAAR ID needs to be more robust with it comes to data privacy, especially given that it would handle data of students who are legal minors.

Given India’s demographic trajectory over the upcoming decades, NEP 2020’s vision for enabling holistic learning at scale, and India’s aspiration for unprecedented economic growth, APAAR and ABC seem to be the right baby steps. All we need to now ensure is that we don’t stumble too much as the baby learns to walk, and not learning from its past mistakes.

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